Hazard Communication Program, workbook

1
Welcome
PURPOSE The purpose of this workshop is to
provide an introduction to the Worker Protection
Standard. To get the most out of this workshop,
please participate fully in all the activities.
We hope you have fun and learn something of
value. GOAL At the end of this workshop you
will be able to 1. Identify the requirements
of the WPS 2. Differentiate between the OR-OSHA
and WPS rules 3. Identify the components of an
effective training team 4. Identify the 8 label
elements of the WPS
2
This workshop was created by Oregon OSHA Salem,
Oregon Contact information Tomas
Schwabe 503-947-7436 tomas.schwabe_at_state.or.us Su
pplies Although not necessary, this workshop
works best if you obtain some items to show and
tell. 1. A WPS poster. 2. A copy of the WPS
video produced by IDAHO. (You dont have to show
the video for this workshop.) 3. A WPS Flip
Chart. 4. A half-face respirator with organic
vapor cartridge and prefilter. 5. A variety of
rubber gloves ie., neoprene, nitirile, PVC, and
Teflon. 6. Copies of the OR-OSHA rules that
govern agriculture OAR 437- Division 4 in either
hard copy or CD-ROM. It never hurts to have the
hard copy in class if someone wants to see the
rule. 7. A copy of the OR-OSHA brochure, Safe
Practices When Working Around Hazardous
Agricultural Chemicals. Continues...
Please Note This material or any other material
used to inform employers of compliance
requirements of Oregon OSHA standards through
simplification of the regulations should not be
considered a substitute for any provisions of the
Oregon Safe Employment Act or for any standards
issued by Oregon OSHA.
3
Instructor You may link to the OR-OSHA WPS
rule by clicking on the link below http//www.cbs.
state.or.us/external/osha/pdf/rules/division_4/div
4w.pdf Instructor You may link to the entire
entire OR-OSHA Division 4 rule, by clicking the
link below http//www.cbs.state.or.us/external/osh
a/pdf/rules/division_4/div4.pdf See page 13 of
the student workbook or page 26 of this
instructor workbook for contact information to
obtain the WPS poster, the IDAHO video and the
flip chart and copies of the Division 4 rule.
The respirator and gloves can be obtained from
any personal protective equipment supplier.
4
Quick Reference Guide to the Worker Protection
Standard (WPS)

• Requirements For Both Workers and Handlers
• Information at a Central Location
• Pesticide Safety Training
• Decontamination Sites
• Notice of Applications to Handler Employers
• Emergency Assistance
• Requirements for Workers
• Restrictions During Applications
• Restricted-Entry Intervals (REIs)
• Posted Warning Signs
• Oral Warnings
• Additional Requirements for Handlers
• Application Restrictions and Monitoring
• Specific Instructions for Handlers

5
The page with the umbrellas represents the 3
part of the WPS standard. The first part of the
WPS represented by the large umbrella has
language that protects BOTH workers and
handlers. The second part of the WPS represented
by the smaller umbrella, has additional
protective language for WORKERS. The third part
of the WPS represented by the other smaller
umbrella, has additional protective language for
HANDLERS. Flip the pages in the workbook and show
the audience that each of the pages has a
miniature of the three umbrellas representing
each of the 3 sections of the WPS. The downward
arrows from the umbrella, shows the audience in
what part of the WPS standard they are. This
page is the outline of the material covered in
the WPS.
6
Special Note

• Agricultural employers with 10 or fewer employees
  are exempt from routine inspections if they meet
  the following criteria (Oregon Revised Statute
  ORS 654.172 and Oregon Administrative Rule OAR
  437-001-0057)
• No accidents resulting in death or serious
  disabling injury occur within the preceding
  two-year period.
• The agricultural place of employment is inspected
  once every four years by an individual acting in
  a safety consultant capacity and the employer has
  corrected the violations noted by the consultant
  within 90 days of receipt of the consultant's
  report.
• The employer and principal supervisors annually
  attend four hours of instruction on agricultural
  safety rules and procedures.

Please remember that the above exemption doesnt
hold for a field sanitation inspection, a labor
camp inspection, a fatality, catastrophe or
accident investigation, or a valid inspection.
The certificate at the back of this workbook
confirms that you attended four hours of safety
instruction. All OR-OSHA workshops meet the
training requirement!
7
The exemption from inspections was passed by the
1995 Oregon Legislature. The 10 or fewer
employees only applies to permanent employees
working either full or part time. If the farm
hires large numbers of migrant workers, these
workers dont count toward the total of 10 or
fewer. If OR-OSHA compliance were to arrive at an
agricultural place of employment to conduct an
inspection and the employer had complied with all
the conditions, the compliance officer would
cease the inspection process and leave. If the
OR-OSHA compliance officer were to observe a
serious or life-threatening hazard during the
time he/she is on site, the compliance officer
would address the hazard and cite the
employer. Question often asked If the farm is
incorporated as a partnership between a husband
and wife, do both have to attend the training?
Answer No, only one it is assumed they couple
will communicate with each other. OR-OSHA has
whats called emphasis program inspections
which override exemptions such as this one.
Currently there is an emphasis program on field
sanitation. In other words, all that is required
for an OR-OSHA compliance officer to stop and
conduct field sanitation inspections is one or
more workers in a field. Usually, the cause for
which a compliance officer will stop to conduct a
field sanitation inspection is the lack of
visible toilet facilities from the road. When a
field sanitation inspection is initiated, a WPS
and a Hazard Communication inspection may
occur. If the instructor isnt with OR-OSHA, you
are responsible for providing your certificate to
the attendees.
8
Introduction

• In Oregon, the
• Occupational Safety and Health Division
• (OR-OSHA)
• administrates occupational
• safety and health related laws.
• OR-OSHAs activities include
• enforcement of the
• Worker Protection Standard
• and other applicable pesticide
• safety and health rules such as
• Hazard Communication,
• Personal Protective Equipment,
• Respiratory Protection, and
• Ventilation.
• You are welcome to your free copy of the
  agricultural occupational safety and health rule
  by calling any of the telephone numbers listed on
  the inside of this workbooks front cover and
  requesting a copy of Division 4 in hard copy,
  CD-ROM,
• or by visiting our
• Web site www.orosha.org

9
Emphasize that the WPS standard is an EPA rule
enforced in Oregon by Oregon OSHA. In other
words, farms, nurseries, greenhouses must comply
with all of the OR-OSHA rules under OAR 437,
Division 4 AND the EPA Worker Protection
Standard. Oregon is the only state in the U.S.
where the OSHA entity in each state enforces BOTH
the OSHA and the WPS. Farms in other states
have two entities governing farm safety OSHA and
EPA. In Washington for example, the OSHA entity
known as WISHA, enforces farm safety and the
Washington Department of Agriculture enforces the
WPS. When Oregon OSHA safety rules are more
protective (stricter) that the WPS, the more
protective rule applies. For example, under the
WPS, the rule says pesticide handlers must be
trained but under the Hazard Communication Rule,
pesticide handlers must be effectively trained.
In other words, in Oregon, handlers must
demonstrate understanding of the training by
answering questions or demonstrating that
theyve actually learned how to handle the
chemical safely. Remind attendees to obtain a
copy of the rule in either CD-ROM, hard copy, or
through our Web page.
10
Does WPS apply to you?
Yes If you employ WORKERS or HANDLERS and
pesticides (herbicides, insecticides, fungicides,
miticides, etc.) have been applied OR a
restricted-entry interval has been in effect
within the last 30 days. If you apply either
restricted or non restricted-use pesticides. If
you apply either restricted or non restricted-use
pesticides in the following circumstances If
you employ WORKERS to perform hand-labor on a
farm, nursery, greenhouse, or forest. If you
employ pesticide HANDLERS on a farm, nursery,
greenhouse, or forest.
11
Go through all the five ifs first. Return to
the first one that has the key on the
margin and remind the audience that for the WPS
to apply, that if must be met. If not met,
NONE of the WPS applies. Example Christmas
tree farmers apply fungicides in February or
March, to kill fungi and moss. However, workers
dont enter the fields to trim the trees into the
classic shapes of cones until May or June. In
other words, the WPS doesnt apply because there
were no workers in the Christmas tree fields
within 30 days of application or the restricted
entry interval. However, Hazard Communication
DOES apply because Hazard Communication applies
its requirements during the ENTIRE growing
season. The pages that follow under the
Training category will cover this difference
further.
12
Does WPS apply to you?
NO If you apply either restricted or non
restricted-use pesticides in the following
circumstances For mosquito abatement, or
similar wide-area public pest control programs
sponsored by government agencies. On livestock
or other animals. On plants grown for other than
commercial or research purposes such as in
habitations, and home fruit and vegetable
gardens. On plants, that are in ornamental
gardens, parks, and public or private lawns and
golf courses. By injection directly into
agricultural plants. Direct injection does not
include hack and squirt, chemigation, soil
incorporation, or soil-injection. For structural
pest control, rights-of-way vegetation control,
and other noncrop areas, pastures and
rangeland. For control of vertebrate pests. As
attractants or repellents in traps. On the
harvested portions of agricultural plants or on
harvested timber.
13
It should be clear from the areas in which the
WPS doesnt apply that the intent of the WPS is
mostly intended to protect migrant and seasonal
workers. Mention this fact to the audience and
illustrate it by pointing to the bullet items
that exempt city parks, golf courses and home
vegetable gardens.
14
Definitions
Hand labor Any agricultural activity performed
by hand or with hand tools that causes a WORKER
to have substantial contact with surfaces (such
as plants, plant parts, or soil) that may contain
pesticide residues. These activities include,
but are not limited to, harvesting, thinning,
weeding, tipping, planting, pruning, and packing
produce into containers in the field. Hand
labor does not include operating, moving, or
repairing irrigation or watering equipment or
performing the tasks of crop advisors.
15
The majority of hand labor working in
agriculture in the U.S. are migrant workers from
Mexico. OR-OSHA offers a workshop, Safety
Training and Your Hispanic Workforce (course
number 499) that addresses language and cultural
barriers to creating a safe work culture in the
workplace. OR-OSHAs course catalog http//www.c
bs.state.or.us/external/osha/pdf/pubs/coursecatalo
g0405.pdf
16
Definitions

• Handler
• Any person, including a self-employed person who
  is
• Mixing, loading, transferring, or applying
  pesticides.
• Disposing of pesticides or pesticide containers.
• Handling opened containers of pesticides.
• Acting as a flagger.
• Cleaning, adjusting, handling, or repairing the
  parts of mixing, loading, or application
  equipment that may contain pesticide residues.
• Assisting with the application of pesticides.
• Entering a greenhouse or other enclosed area
  after the application and before the inhalation
  exposure level listed in the labeling has been
  reached or one of the ventilation criteria
  established by this standard or in the labeling
  has been met
• To operate ventilation equipment.
• To adjust or remove coverings used in fumigation.
• To monitor air levels.
• Entering treated area outdoors after application
  of any soil fumigant to adjust or remove soil
  coverings such as tarpaulins.
• Does not include handling pesticide containers
  that have been emptied or cleaned according to
  pesticide product labeling instructions or in
  absence of instructions, have been triple-rinsed
  or its equivalent.

17
If you ask the audience what crops they grow and
the kind of application methods to use to apply
chemicals, youll get a better idea of your
audience. Dont be surprised to find a number of
structural pest applicators in your workshop.
This workshop is endorsed by the Oregon
Department of Agriculture and provides 4 Core
credit hours to the Recertification of
applicators licenses. If people have questions
about their applicators licenses, refer them to
the Oregon Department of Agriculture Pesticides
Division Phone [phone] Ask for someone in
the Pesticides Division. As of 3-15-05, Laurie
Gordon is good person to ask for. Her direct
number is 503-986-4789. Ags Web page
http//www.oregon.gov/ODA/index.shtml
18
Protection For Both Workers and Handlers

• Information at a Central Location
• In an easily seen central location on each
• agricultural establishment, display close
  together
• Pesticide safety poster.
• Name, address, and telephone number of the
• nearest emergency, medical facility or 911 if
  used.
• These facts about each pesticide application
• from BEFORE each application begins until
• 30 days AFTER the restricted-entry interval
  REI
• Product name, EPA registration number,
• and active ingredient(s).
• Location and description of treated area.

19
Its not required, but you may consider using a
WPS poster, a large 911 sign and the
Application List (found in the appendix of this
workbook) as props and post these three items on
a wall at the location where the class is being
conducted. Mention that the Application List
requires that the long chemical name be listed
(Not just the name of the product). People may
ask why. The answer is that this name becomes
very important to medical providers in the event
of an emergency Mention that the Application
List shows that the chemical application takes 3
hours. Three hours is only an example. Actual
time of application will vary. The important
thing to mention is that the Restricted Entry
Interval (REI) starts after the application of
the chemical is completed and not when it begins.
20
Protection For Both Workers and Handlers

• Pesticide Safety Training
• Unless handlers possess a certified applicators
  license, train handlers and workers before they
  perform pesticide handling tasks and at least
  once every 5 years
• Use written and/or audiovisual materials.
• Use EPA WPS handler training materials for
  training handlers.
• Use EPA WPS worker training materials for
  training workers.
• Conduct the training orally and/or audiovisually
  in a manner the employees can understand, using
  easily understood terms, and respond to questions.

When to train Train ALL workers BEFORE the 6th
day. Prior to entry to the fields, train workers
on the basic elements as covered in the brochure
Safe Practices When Working Around Hazardous
Agricultural Chemicals. Handlers Need Hazard
Communication in addition to WPS. If someone
is a Certified Applicator, they must still be
trained on Hazard Communication !
21
If a student receives training on WPS once every
5 years they will be in compliance with the WPS
rule. However, it isnt likely that the workers
and handlers will remember what they learned in
the 2nd, 3rd and 4th years. Hazard Communication
however, requires worker who work with chemicals
be trained effectively. Therefore, OR-OSHA
recommends that at a minimum, employers verify
that workers know the health and physical effects
of the chemicals, the PPE requirements and what
to do in the event of an emergency. It enhances
the workshop if you can show the audience a copy
of the audiovisual materials used to train the
WPS.
22
Training Difference Between The Hazard
Communication Rule and The Worker Protection
Standard for Workers
Hazard Communication training for Workers.
Hazard Communication must be completed before
workers enter fields.
Worker Protection Standard for Workers.
WPS training must be completed before 6th day
workers enter fields.
23
Theres two training requirements for workers
and handlers. One is Hazard Communication, the
other is WPS. Hazard Communication training must
occur BEFORE workers place a foot onto a field.
Under Hazard Communication, it doesnt matter
when pesticides are applied to the field as long
as pesticides have been applied to the field
during the current growing season, the workers
shall receive a copy of the Brochure and have
access to the MSDSs. WPS training must occur
BEFORE workers place a foot onto a field on the
6th day (Doesnt have to be consecutive days).
Unlike Hazard Communication, WPS applies only if
pesticides have been applied or an REI has been
in effect within the last 30 days. Point to the
picture of the training taking place. Bring
attention to the person in the audience with his
hand raised asking a question. Herein is the
biggest difference between Hazard Communication
and WPS. Under WPS, workers are trained
interactively in the language used to communicate
with the workers. Contrast this with Hazard
Communication where just providing the worker a
copy of the Brochure and telling them of the
location and availability of the MSDSs is all the
training required. Many farms in Oregon conduct
both Hazard Communication and WPS training
simultaneously, usually on a day soon after they
are hired and before anyone goes to work in the
fields.
24
Training Limited English-Speaking Workers
LANGUAGE LEADER The person with the best English
communication skills SOCIAL LEADER The person
the group sees as their leader the person they
trust the most TECHNICAL LEADER The person with
the best job and safety related knowledge and
skills
Train with a team !
25

• Job training for limited-English Hispanic workers
  in many Oregon workplaces often happens like
  this
•  
• The trainer, usually a native English speaker
  without bilingual skills, grabs a native Spanish
  speaker with some English skills from the group
  of workers, and uses this person as an
  interpreter.
•  
• The training begins with the trainer speaking
  through the interpreter.
•  
• Sometime during the training session, the trainer
  asks the trainees if there are any questions.
•  
• The trainees hardly ever have any questions.
•  
• The training ends with the trainer asking the
  trainees if they understood everything.
•  
• The trainees nod their heads in a yes motion,
  indicating they understood everything.
• They didnt.
• When formal training takes place its very
  important to bring together a team of people to
  ensure that the training is successful. This is
  a accomplished by bringing together 3 key people
  The Language, the Social, and the Technical
  Leaders. It may happen that the the language
  leader and the social leader or the technical
  leader are the same person. If this is the case,
  the employer is lucky to have such a person as a
  member of their training team.

26
The Language Leader can be a worker, a foreman,
a supervisor or a professional interpreter. If
the job is complex and requires multiple safety
measures, it may be very important to obtain the
services of a professional interpreter. Without
the Language Leader as a member of the training
team, communication will likely be limited to
hand signs. The Social Leader is usually one
of the workers. This person may be the
individual who helped the workers get to Oregon
from Latin America, someone in high standing in
the groups home village, or simply, the person
recognized as the one who makes the important
group decisions or who influences
others. Without the Social Leader as a member of
the training team, the group may not trust what
is being communicated. If the Social Leader is
excluded from the training team and he or she and
the Language Leader dont trust each other, the
training session could be undermined by the
Social Leader with just a few glances to
coworkers. The Technical Leader can be the
owner, the foreman, the supervisor, or the person
with the most experience. The Technical Leader
must have two important qualities He or she
must know how to do the job well and be able to
do it safely high production but without safety
shortcuts! Without the Technical Leader as a
member of the training team the best and safest
way to do the job will not be communicated. It
is harder to relearn to do something right than
to be taught to do it right the first
time. Continues on next page...
27
The critical element of these 3 key people is
that they DEMONSTRATE by actions what the
workers are expected to do and how they are going
to accomplish this task safely! Trainers of
workers and handlers should use props, should
demonstrate, should ask for volunteers to repeat
the training. The trainers should be 100 percent
certain that the workers know how to do the job
and how to do it safely!
28
Training Resources and Materials

Agriculture Division 4 (OR-OSHA Rule) The OR-OSHA
Code for Agriculture. In paper or CD-ROM. (Free
from OR-OSHA) Pesticide Safety - Worker
Protection II (Video) Produced by the University
of Idaho. The video contains both English and
Spanish version of training for agricultural
workers and pesticide handlers. OR-OSHA VIDEO
NUMBER 323 (Borrow from OR-OSHA, Obtain from EPA,
or Purchase from University of Idaho or
GEMPLERS). How to Conduct Worker Protection
Training/Train-the-Trainer (Video) Condensed
version of the December 16, 1993, AGSAT broadcast
of the Train-the- Trainer, EPA approved course
for the Worker Protection Standard. OR-OSHA VIDEO
NUMBER 352 (Borrow from OR-OSHA). Protect
Yourself from Pesticides - Safety Training for
Agricultural Workers. (Flip Chart) The flip
chart used for worker training - bilingual,
English and Spanish. (Obtain from EPA, or
Purchase from GEMPLERS). Worker Protection
Standard Poster Required poster in all workplaces
covered by the WPS. (Obtain from EPA, or Purchase
from GEMPLERS).
University of Idaho 1997 846 Order
7034 35.00 208.885.7982 Fax [phone] Email
agpubs_at_uidaho.edu Catalog http//info.ag.uidaho.e
du/catalog/catalog.html
Oregon OSHA Resource Center 350 Winter St.
NE Salem, OR 97310 [phone] (800)
922-2689 www.orosha.org
GEMPLERS PO Box 270 Mt. Horeb, WI 53572 (800)
382-8473 www.gemplers.com
Environmental Protection Agency
(EPA) 1-800-490-9198 or fax at 1-513-489-8695.
http//www.epa.gov/oppfead1/Publications/catalog/s
ubpage7.htm http//www.epa.gov/oppfead1/safety/wor
kers/amendmnt.htm
29
The phones and addresses and Web addresses on
this page are current as of April 1, 2005.
30
Protection For Both Workers and Handlers

• Decontamination Sites
• Establish a decontamination site within 1/4 mile
  of all workers and handlers (similar to the Field
  Sanitation Rule). Supply
• Enough water for routine and emergency
  whole-body washing and for eye flushing.
• Plenty of soap and single-use towels.
• A clean coverall for handlers.
• Provide water that is safe and cool enough for
  washing, for eye flushing, and for drinking. Do
  not use tank-stored water that is also used for
  mixing pesticides unless they have working
  back-flow devices.
• Provide handlers the same decontamination
  supplies at the location where personal
  protective equipment (PPE) is removed at the end
  of a task.
• Provide the same supplies at each mixing and
  loading site.
• Make at least 1 pint eye flush water immediately
  accessible to each handler.
• Do not put worker decontamination sites in areas
  being treated or currently under an REI. If the
  decontamination supplies must be in the treated
  area because of travel distance, place the
  supplies in a closed container that is washable.

Tupperware type container works well because
you can easily wash it off before opening.
31
One quarter mile can be described by a person
walking at a leisurely pace for 5 minutes in a
farming field. Within this radius, there must be
a decontamination facility. This is also the
distance at which there needs to be the required
items under the Field Sanitation Rule - Portable
toilet at a ratio of 1-20, handwashing water,
soap and disposable towels, and drinking water
with disposable cups. For water to be safe it
must be able to pass the Oregon Health Division
potability standards. Dont recommend using ice
to keep water cool. Ice just introduces a
potential contaminant. Fill coolers with cool
water and keep it/them in the shade. How much
water should be on hand? Employers need to
determine the days water needs for BOTH drinking
and decontamination depending on number of
workers, the days temperature and the type of
work being done. EYE WASH The Worker
Protection Standard requires a one pint eye flush
bottle for splashes of pesticides into the eyes.
Although this meets the requirements of the WPS,
it fails to meet the label requirements which
require the eyes be continually flushed for 15
minutes. Currently Division 4, Agriculture,
exempts pesticides from the Emergency eyewash
requirements, due to the Worker Protection
Standard. Products capable of severely damaging
the eye are denoted on the label, DANGER-TOXIC OR
DANGER-CORROSIVE. It is highly recommended that
an emergency eyewash station be provided when
using this type of chemicals. The emergency
eyewash must be capable of providing a continuous
flow of water for 15 minutes to both eyes. The
emergency eyewash stations should be immediately
available wherever products are either mixed or
loaded which have the potential to cause
permanent eye damage.
Plumbed
Portable
32
Protection For Both Workers and Handlers

• Notice of Applications by Handler Employers
• Before any application, commercial handlers hired
  by a grower must make sure the operator of the
  agricultural establishment where a pesticide will
  be applied is aware of
• Location and description of area to be treated.
• Time and date of application.
• Product name, EPA registration number, active
  ingredient(s), and REI.
• Whether the product label requires both oral
  warnings and treated area posting.
• All other safety requirements on labeling for
  workers or other people.
• Operators of agricultural establishments must
  make sure any commercial pesticide operator they
  hire is aware of
• Specific location and description of all areas on
  the agricultural establishment where pesticides
  will be applied or where an REI will be in effect
  while the commercial handler is on the
  establishment.
• Restrictions on entering those areas.

33
The commercial handler is the one that has
possession of the label and therefore, the one
that needs to provide the information that the
employer needs to post at the central
location. Although not a part of the WPS, its
also the commercial handler that should have the
MSDSs which the employer also needs to have
available to his/her workers.
34

Protection For Both Workers and Handlers

• Product name, EPA registration number, active
  ingredient(s).
• All first aid and medical information from label.
• Description of how the pesticide was used.
• Information about victims exposure.
• Although not an element of WPS, this is the
  perfect place to include the Material Safety Data
  Sheet (MSDS) required by the Hazard
  Communication Rule and the Pesticide Label.

LABELS AND MSDSs on the WEB A very good website
for pesticide labels and MSDSs is Crop Data
Management Systems. CDMS, Inc. is a privately
held corporation located in Marysville, CA.
Founded in 1983, the company provides software
service to access crop protection product label,
MSDS, WPS and DOT information. http//www.cdms.ne
t/manuf/manuf.asp
35
In remote areas, it may be necessary for the
employer to provide transportation on the way to
meet the ambulance. Employers should contact
their local emergency services to discuss
emergency plans based on the likely emergencies
they are likely to encounter. Point out that the
product name, EPA registration number, active
ingredient(s) can be readily obtained from the
Central Posting Location. THIS IS THE END OF THE
SECTION OF THE RULE THAT COVERS BOTH WORKERS AND
HANDLERS. THE NEXT SECTION COVERS ADDITIONAL
PROTECTION FOR WORKERS.
36
Additional Protection for Workers

• Restrictions During Applications
• In areas being treated with pesticides, allow
  entry only to appropriately trained and equipped
  handlers.
• In nursery settings, keep workers at least 25-100
  feet away from nursery areas being treated,
  depending on treatment method.
• Allow only handlers to be in a greenhouse
• during a pesticide application.
• until labeling-listed air concentration level is
  met or, if no such level, until after 2 hours of
  ventilation with fans.
• Special application aeration requirements apply
  to greenhouses when fumigant is applied.
• Restricted-Entry Intervals (REIs)
• During any REI, do not allow workers to enter
  treated areas for the amount of time specified on
  the label.
• Always orally warn workers and post treated areas
  if the pesticide label requires.

37
Point out that the arrow on the umbrellas has
moved from the big to the small.
Treatment Method We normally provide this
information if asked. Otherwise, we tell the
audience to consult the label. The chart below
was obtained at the following address on the
EPAs Web Page http//www.epa.gov/oppfod01/safety
/workers/equip.htm
Entry-Restricted Areas in Nurseries During
Pesticide Applications
Workers and other persons are prohibited in
During Application of a Pesticide
(1)(a) Applied aerially, in an upward direction,
or using a spray pressure greater than 150 psi
(pounds per square inch), or(b) Applied as a
fumigant, smoke, mist, fog, or aerosol
Pesticide treated area plus 100 feet in all
directions on the nursery
(2)(a) Applied downward using a height of
greater than 12 inches from the planting medium,
a fine spray, or a spray pressure greater than 40
psi and less than 150 psi.(b) Not as in 1 or
2(a) above, but for which a respiratory
protection device is required for application by
the product labeling
Treated area plus 25 feet in all directions on
the nursery
(3) Applied otherwise
Pesticide treated area
Continues on next page...
38
Basically this section of the standard can be
summarized in a few simple ways Workers, get
out OUT! Workers, you are not trained or equipped
to be in or near the treated areas. Leave.
Dont return until we tell you its safe!
There are several chemicals which DO NOT
specify which way to communicate with the
employees as to the REIs. Tell the audience that
some of these chemicals surprisingly include
pesticides with Danger-Poison on the label. Tell
the audience over and over and over READ THE
LABEL! Take a look a the EPAs main site for
worker safety and health to get a feel for the
WPS but also to see lots of helpful related items
such as heat stress when working with PPE and
also to read more recent updates to the
rule http//www.epa.gov/pesticides/health/worker.
htm
39
Additional Protection for Workers

• Notice About Applications
• Post legible 14 x 16 WPS-design signs just
  before application
• keep posted during REI remove sign before
  workers enter and within 3 days after the end of
  the REI. A smaller sign is approved for nursery
  sites.
• Post signs so they can be seen at all entrances
  to treated areas,
• including entrances from labor camps.
• Oral Warnings
• Before each application, tell workers who are on
  the establishment (in a manner they can
  understand)
• Location and description of treated area.

40
Read requirements. THIS IS THE END OF THE
SECTION OF THE RULE THAT COVERS ADDITIONAL
PROTECTION FOR WORKERS. THE NEXT SECTION COVERS
THE ADDITIONAL PROTECTION FOR HANDLERS.
41
Additional Protection for Handlers

• Application Restrictions and Monitoring
• Do not allow handlers to apply a pesticide so as
  to contact, directly
• or through drift, anyone other than properly
  trained and PPE-equipped handlers.
• Make sight or voice contact at least every 2
  hours with anyone handling pesticides labeled
  with a skull and crossbones.
• Make sure a trained handler equipped with
  labeling-specified PPE maintains constant voice
  or visual contact with any handler in a
  greenhouse who
• is doing fumigant-related tasks, such as
  application or air-level monitoring.
• Specific Instructions for Handlers
• Before handlers do any handling tasks (mix, load,
  apply), inform them in a manner they can
  understand, of all pesticide labeling
  instructions for safe use.

42
Point out that the arrow on the umbrellas has
moved from the small left side to the small right
side. When covering the Specific Instructions
for Handlers especially the part of informing
them in a manner they can understand, of all
pesticide labeling instructions for safe use,
remind them of the importance of using
demonstration and the team approach using the
language, social, and technical leader.
43
Additional Protection for Handlers

• Equipment Safety
• Inspect pesticide handling equipment before each
  use, and repair or
• replace as needed.
• Allow only appropriately trained and equipped
  handlers to repair, clean,
• or adjust pesticide equipment that contains
  pesticides or pesticide residues.
• Personal Protective Equipment (PPE)
• Provide handlers with the PPE the pesticide
  labeling requires for
• the task, and be sure it is
• clean and in operating condition.
• worn and used correctly.

OR-OSHA HAS ADDITIONAL PPE RULES! EXAMPLE
OR-OSHA REQUIRES A MEDICAL QUESTIONNAIRE AND FIT
TESTING FOR WORKERS USING RESPIRATORS. PLEASE
CALL 800-922-2689 ENGLISH 800-843-8086
SPANISH OR WWW.OROSHA.ORG FOR YOUR COPY OF
OR-OSHA DIVISION 4
44
This section introduces the subject of PPE. It
gives you, the instructor a lot of latitude as to
what examples and props you want to use to
illustrate the subject of selection and use of
PPE. If you know of personal or professional
stories of misuse of PPE, this is the time to
mention them. Ask the class openly How do you
select the gloves you use? Something thats
useful to discussion started is to ask If you
wear gloves and long sleeved shirt, does the
shirt sleeve go over the glove, or the glove over
the shirt? Three (3) correct answers Answer
If spraying downward, sleeve over glove.
(Demonstrate your arms pointing downward toward
the floor.) Spray lands on sleeve and drips
downward over the glove, not into the
glove. Answer If spraying upward, glove over
sleeve. (Demonstrate your arms pointing upwards
toward the ceiling.) Spray lands on the glove and
drips downward over the sleeve, not into the
sleeve. Answer If spraying both upward and
downward, bind the glove and sleeve with duct
tape. Yes, good old duct tape! On the subject
of PPE I find it useful to print the EPAs
Chemical Resistance Category Chart and distribute
a copy to the class. http//www.epa.gov/oppfod01/s
afety/workers/equip.htm
Continues on next page...
45
Where it says the respirators must fit
correctly... This means fit testing as per
Division 4. OAR 437-004-1040 Instruction of
supervisors and workers must be by competent
persons. Include an opportunity to handle the
respirator, have it fitted properly, test its
face-piece-to-face seal, wear it in normal air
for a long familiarity period and finally, to
wear it in a test environment. Division 4 does
NOT require that workers complete the medical
questionnaire. However, OAR 437-004-1040 says
this Do not assign workers to tasks requiring
use of respirators unless they are physically
able to do the work and use the equipment. A
physician must make the determination based on
the appropriate health and physical standards.
Periodically review the respirator user.s medical
status. (At least, annually.) The employer must
give the physician the appropriate information
about the worker to facilitate the
examination. At this point, you may encourage
employers to utilize the questionnaire and let
them know that its available on the OR-OSHA web
page in both Spanish and English
http//www.cbs.state.or.us/external/osha/pdf/rules
/division_4/div4i.pdf Go to pages 9 through 23.
46

• New WPS Glove Requirements
• for Workers, Handlers, and Pilots
• All agricultural pesticide handlers and
  early-entry workers covered by the Worker
  Protection Standard are now permitted to wear
  separate glove liners beneath chemical-resistant
  gloves.
• Agricultural pilots do not have to wear
  chemical-resistant gloves when entering or
  exiting aircraft.
• Handlers and early entry workers may choose
  whether to wear the liners.
• The liners may not be longer than the
  chemical-resistant glove, and they may not extend
  outside the glove.
• The liners must be disposed of after 10 hours of
  use, or whenever the liners become contaminated.
• Lined or flocked gloves, where the lining is
  attached to the inside of the chemical-resistant
  outer glove, remain unacceptable.
• Regulatory action was taken to reduce the
  discomfort of unlined chemical resistant gloves,
  especially during hot or cold periods.

47
These changes were made by EPA in November 2004.
48
Additional Protection for Handlers

• Provide handlers a pesticide-free area for
• storing personal clothing not in use.
• putting on PPE at start of task.
• taking off PPE at end of task.
• Do not allow used PPE to be worn home or taken
  home.
• Care of PPE
• Store and wash used PPE separately from other
  clothing and laundry.
• If PPE will be reused, clean it before each day
  of reuse, according to the instructions from the
  PPE manufacturer unless the pesticide labeling
  specifies other requirements. If there are no
  other instructions, wash in detergent and hot
  water.
• Dry the clean PPE before storing, or hang to dry.

49
Many workers wear baseball caps and other types
of hats. Its rare that these items ever get
washed. Let the audience know that baseball caps
and hats are not PPE against chemicals unless
specifically designed and used for that
purpose. Encourage the audience to wash caps and
hats regularly.
50
Additional Protection for Handlers

• Replacing Respirator Purifying Elements
• Replace dust/mist filters
• when breathing becomes difficult.
• when filter is damaged or torn.
• when respirator label or pesticide label requires
  (whichever is shorter), OR at the end of days
  work period, in the absence of any other
  instructions or indications.
• Replace vapor-removing cartridges/canisters
• when odor/taste/irritation is noticed.
• when respirator label requires (whichever is
  shorter), OR at the end of days work period, in
  the absence of any other instructions or
  indications.

51
This is pretty clear. It works for purposes of
the WPS but theres more information than this in
OR-OSHA Division 4, Respirator Section. It may
useful to print the whole section on PPE (its 30
pages). Staple it, and pass it around the class
so they can take a look at the whole requirement
on PPE and Respirators. http//www.cbs.state.or.u
s/external/osha/pdf/rules/division_4/div4i.pdf
52
Additional Protection for Handlers

• Disposal of PPE
• Discard coveralls and other absorbent materials
  that are contaminated with undiluted pesticide
  having a DANGER or WARNING signal word.
• Follow Federal, State, and local laws when
  disposing of PPE that cannot be cleaned
  correctly.
• Instructions for People Who Clean PPE
• Inform people who clean or launder PPE
• That PPE may be contaminated with pesticides.
• The potentially harmful effects of exposure to
  pesticides.
• How to protect themselves when handling PPE.
• How to clean PPE correctly.

53
You may find it useful to encourage the class
audience to try and Make their workplaces a
language and cultural learning zone. One
successful employer in the Oregon mid-Willamette
valley, has contracted with an interpreter who
works at the farms main office once a day. The
interpreter is hired to handle all sorts of
issues for the workers who dont speak English
such as correspondence from their insurance
companies, utilities, and medical offices. The
interpreter makes phone calls, clarifies issues
between the parties helps resolve problems.
Workers at this farm find that the service make
working for this employer is like working at
home. Employer ideas Get a wall-sized map of
Mexico and colored push pins and place pins from
the home locations of your workers. Then get a
travel book at the library about that state,
learn something about each of those states of
Mexico, and then talk to them about it. They
will be VERY surprised and pleased. Tape weekly
soccer games and soap operas on the Spanish T.V.
channel and play back the tapes during lunch.
Watch what happens! If you connect with the
workers in their culture, it will pay off for you
in higher morale, and productivity. Purchase
some learn English tapes and a tape-player and
offer to anyone who wants to practice English
during their breaks or lunch periods. Your
workers are thousands of miles from home in a
country that speaks a different language and
culture. Anything you do to make your workplace
seem a little like home to your workers will pay
off - guaranteed!
54
1. APPLICATION RESTRICTION STATEMENT Do not
apply this product in a way that will contact
workers or other persons, either directly or
through drift. Only protected handlers may be in
the area during application. Label
location DIRECTIONS FOR USE. 2. 40 CFR PART
170 REFERENCE STATEMENT Use this product only
in accordance with its labeling and with the
Worker Protection Standard, 40 CFR part
170. Label location AGRICULTURAL USE
REQUIREMENTS. 3. PRODUCT-TYPE IDENTIFICATION
STATEMENT N-methyl carbamates, organophosphates,
and fumigants must be identified as
such. Label location Either near the
product name, product-type Identification or
in the STATEMENT OF PRACTICAL TREATMENT or
FIRST AID TREATMENT Fumigants must be
identified as part of, or close to, the
product name. 4. STATE RESTRICTIONS For any
requirements specific to your State or Tribe,
consult the agency responsible for pesticide
regulation. Label location DIRECTIONS
FOR USE. 5. SPANISH WARNING STATEMENT If the
product is classified as Tox I (Danger) or Tox II
(Warning), the signal word shall appear in
Spanish and English followed by the statement,
Si usted no entiende la etiqueta, busque a
alguien para que se la explique a usted en
detalle. (If you dont understand the label,
find someone to explain it to you in
detail). DANGER PELIGRO WARNING
AVISO Label location Close to the product
name.
55
6. RESTRICTED ENTRY STATEMENT Do not enter or
allow worker entry into treated areas during the
restricted-entry interval (REI). If only one
REI, it must be listed after the above statement
in the Agriculture use box. If more than one
REI for different crops, the REI will be
associated with the directions for use for each
crop and identified as such (example, 24 hour
REI). Most ranges are 4 hours to 72
hours. Label location AGRICULTURAL USE
REQUIREMENTS. 7. NOTIFICATION-TO-WORKERS
STATEMENT TOXICITY I for acute dermal toxicity
or skin irritation shall state Notify workers
of the application by warning them orally and
by posting warning signs at entrances to treated
areas. For fumigants used in green houses shall
state For greenhouse application by warning
them orally and by posting warning signs outside
all entrances to the greenhouse. For any
pesticide other than those for which the labeling
requires both posting and oral notification of
applications and the label is silent on
notification, the agricultural employer shall
give notice of the application to the worker
either by the posting of warning signs or
orally. The workers shall be informed which
method of notification is in effect. Label
location AGRICULTURAL USE REQUIREMENTS. 8.
PERSONAL PROTECTIVE EQUIPMENT STATEMENT These
requirements are for all handlers of the product
for all uses unless the exceptions are clearly
identified and are located in two locations on
the label. Label location a) PPE for
Handlers will be in the HAZARDS TO HUMANS AND
DOMESTIC ANIMALS. b) PPE for EARLY
ENTRY WORKERS will be placed in the
AGRICULTURAL USE REQUIREMENTS and
immediately after the REI statement.
56
Take a few minutes and identify and review each
of the 8 key elements of the WPS on any pesticide
label. Depending on the class and the time
remaining you can ask the attendees to find each
of the 8 elements or you can direct them to their
locations. Emphasize the element of PPE.
Identify that there are 2 locations on the label
where PPE can be found. The first is for the
applicator/handler and the second is in the
Agriculture Use Box for early entry workers.
You should emphasize that the label is the LAW!
If OR-OSHA does an inspection and finds that
handlers and early entry workers are not using
the labeling required PPE, they will be cited!!
57
RESTRICTED USE PESTICIDE Due to acute oral,
dermal and inhalation toxicity and avian
hazards. For retail sale to and use only by
Certified Applicators or persons under their
direct supervision and only for those uses
covered by the Certified Applicator's
certification.
20 Granular Systemic Low-Odor
Insecticide ACTIVE INGREDIENT Phorate
(O,O-diethyl -S-(ethylthio)methyl-
phosphorodithioate)........... 20.0 INERT
INGREDIENTS ......................................
..................................... 80.0 TOTAL
..................................................
................................................
100.0 STOP--READ LABEL BEFORE USING KEEP OUT
OF REACH OF CHILDREN DANGER
POISON PELIGRO VENENO Si usted no
entiende la etiqueta, busque a alguien para que
se la explique a usted en detalle. (If you do not
understand this label, find someone to explain it
to you in detail.) STATEMENT OF PRACTICAL
TREATMENT ORGANOPHOSPHATE FIRST AID TREATMENT
Call a doctor (physician), clinic, or hospital
immediately. Explain that the victim has been
exposed to Phorate and describe his condition. IF
BREATHING HAS STOPPED, start artificial
respiration immediately and maintain until doctor
sees victim. IF SWALLOWED, call a physician or
poison control center. Drink 1 or 2 glasses of
water and induce vomiting by touching back of
throat with finger, or if available, by
administering syrup of ipecac. DO NOT INDUCE
VOMITING OR GIVE ANYTHING BY MOUTH TO
AN UNCONSCIOUS PERSON. IN CASE OF CONTACT,
immediately flush eyes or skin with plenty of
water for at least 15 minutes. See doctor
immediately. Read Additional PRECAUTIONARY
STATEMENTS. EPA Reg. No. 9779-293 EPA Est.
No. 34704-NE-1 Manufactured For Terra
International, Inc. NET CONTENTS P.O. Box
6000, Sioux City, Iowa 51102-6000 LBS. Riverside
Serves Agriculture. AgricuIture Serves
Everyone. 9/A07/8
LABEL MODIFIED FOR TRAINING PURPOSES
5
3
58
PRECAUTIONARY STATEMENTS HAZARDS TO HUMANS AND
DOMESTIC ANIMALS DANGER CAN KILL IF
SWALLOWED This product can kill you if
swallowed, even in small amounts spray mist may
be fatal if swallowed CAN KILL BY SKIN
CONTACT This product can kill you if touched by
hands or spilled or splashed on skin, in eyes or
on clothing (liquid goes through clothes). CAN
KILL IF BREATHED This product can kill you if
vapors or spray mist are breathed. WORK SAFETY
RULES REPEATED EXPOSURES TO CHOLINESTERASE
INHIBITORS SUCH AS ARE CONTAINED IN THIS PRODUCT
MAY, WITHOUT WARNING, CAUSE PROLONGED
SUSCEPTIBILITY TO VERY SMALL DOSES OF ANY
CHOLINESTERASE INHIBITOR. Persons working with
this product should have frequent blood tests of
their cholinesterase levels. If the
cholinesterase level falls below a critical
point, no further exposure should be allowed
until it has been determined by means of blood
tests that the cholinesterase level has returned
to normal. Before using this product, consult the
National Pesticide Telecommunications Network for
recommendations regarding such blood tests,
poisoning management, emergency treatment, and
other information regarding the toxicity of
Phorate. The toll free number for the National
Pesticide Telecommunications Network
is 1-800-858-7378. If handled indoors provide
mechanical exhaust ventilation. Do not rub eyes
or mouth with hands. If you feel sick in any way,
STOP work and get help right away. See First Aid
(Practical Treatment) section. POISON SIGNS
(Symptoms) Phorate is a very dangerous poison. It
rapidly enters the body on contact with all skin
surfaces and eyes. Exposed persons must receive
prompt medical treatment or they may die. Some of
the signs and symptoms of poisoning are headache,
nausea, vomiting, cramps, weakness, blurred
vision, pin-point pupils, tightness in chest,
labored breathing, nervousness, sweating,
watering, of eyes, drooling or frothing of mouth
and nose, muscle spasms and coma.
59
NOTE TO PHYSICIAN Antidote - administer atropine
sulfate in large doses. TWO to FOUR mg.
intravenously or intramuscularly as soon as
cyanosis is overcome. Repeat at 5 to 10 minute
intervals until signs of atropinization appear.
2-PAM chloride is also antidotal and may be
administered in conjunction with atropine. DO NOT
GIVE MORPHINE OR TRANQUILIZERS. Phorate is a
strong cholinesterase inhibitor affecting the
central and peripheral nervous systems and
producing cardiac and respiratory depression. At
first sign of pulmonary edema, the patient should
be given supplemental oxygen and treated
symptomatically. Continued absorption of the
poison may occur and fatal relapses have been
reported after initial improvement. VERY CLOSE
SUPERVISION OF THE PATIENT IS INDICATED FOR AT
LEAST 48 HOURS. Personal Protective
Equipment Applicators and other handlers must
wear chemical-resistant protective suit,
waterproof loves, chemical-resistant footwear
plus socks, protective eyewear,
chemical-resistant headgear for overhead
exposure, and a respirator with either an organic
vapor-removing cartridge with a prefilter
approved for pesticides (MSHA/NIOSH approval
number prefix TC-23C), or a canister approved for
pesticides (MSHA/NIOSH approval number prefix
TC-14G). Discard clothing and other absorbent
materials that have been drenched or heavily
contaminated with this product's concentrate. Do
not reuse them. Follow manufacturer's
instructions for cleaning/maintaining PPE. If no
such instructions for washables, use detergent
and hot water. Keep and wash PPE separately from
other laundry. Engineering Controls
Statement When handlers use closed systems,
enclosed cabs, or aircraft in a manner that meets
the requirements listed in the Worker Protection
Standard (WPS) for agricultural pesticides 40
CFR 170.240 (d) (4-6), the handler PPE
requirements may be reduced or modified
as specified in the WPS. DURING AERIAL
APPLICATION, HUMAN FLAGGERS ARE PROHIBITED UNLESS
IN A TOTALLY ENCLOSED VEHICLE. USER SAFETY
RECOMMENDATIONS Users should wash hands before
eating, drinking, chewing gum, using tobacco or
using the toilet. Remove clothing immediately if
pesticide gets inside. Then wash thoroughly and
put on clean clothing. Remove PPE immediately